Modern Slavery Statement

Modern Slavery and Human Trafficking Statement

This statement sets out The City of Liverpool College’s actions to understand all potential modern slavery risks related to its business, and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its business and supply chains.

This statement relates to actions and activities during financial years 1 August 2015 to 31 July 2016, and 1 August 2016 to 31 July 2017.

The City of Liverpool College Group recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The City of Liverpool College Group is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of The City of Liverpool College and its three subsidiary companies, namely:Shared Services, First4Skills and Liverpool Business Services. The College has a learner population of approximately 25,000 and a turnover of approximately £50 million.

The City of Liverpool College Group has a diverse supply chain covering staffing resources and operational activities, including, but not limited to, estates management, cleaning, and transport.

The City of Liverpool College Group is aware of its legal responsibility, and is developing its framework to ensure its supply chain complies with the Act. This includes policies, risk assessment, due diligence and training requirements.

Relevant Policies

The City of Liverpool College has a number of policies that assist in preventing slavery and human trafficking in its operations, including:

1. Whistleblowing Policy

The City of Liverpool College Group encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. The Whistleblowing Procedure is designed to make it easy for workers to make disclosures without fear of retaliation.

2. Safeguarding Policy

The City of Liverpool College provides advice and guidance to staff that includes references to modern slavery and trafficking in the form of published guidance and formal staff training. The legislation and its implications for practitioners and students will be clarified in the College’s Safeguarding Policy and is covered in the associated Safeguarding Guidance documentation. In addition, it is fully covered in face to face staff training packages during staff induction and in advanced training offered to key staff.

3. Procurement Policy

The City of Liverpool College Group is committed to ensuring that its suppliers adhere to the highest standards of ethics, and a review of its Terms & Conditions will be undertaken to ensure that existing suppliers are aware of their obligations under the Act and comply where necessary. All new suppliers will be vetted for compliance with the regulations, as part of the due diligence process. Training will be delivered for key staff and budget holders.

Any supplier, or potential supplier, that does not comply with the Modern Slavery Act 2015, or the College’s own policies and procedures, will be removed from the College’s list of suppliers. They will not be considered for future supply to the College unless they can demonstrate that these compliance requirements are met.

4. Recruitment & Selection Policy

The City of Liverpool College Group uses reputable employment agencies to source staffing requirements. It verifies the practices of any new agency used before accepting workers from that agency, and will review terms and conditions of existing agencies to ensure that they are aware of their obligations under the act.

The College ensures that all approved recruitment agencies conduct all relevant pre-recruitment checks and provide evidence that all such checks have been conducted.

5. Anti-Bribery and Corruption Policy

The City of Liverpool College Group is committed to the highest standards of ethical conduct and integrity in its business activities. The College will not tolerate any form of bribery or corruption by its employees or any person or body operating on its behalf.

Due Diligence

The City of Liverpool College Group undertakes appropriate financial and due diligence checks when considering taking on new suppliers, and regularly reviews its existing suppliers to ensure they meet their regulatory obligations.

Changes have been made to the New Supplier Application Form so that suppliers can provide evidence that they comply with the Act, and thereby the College can seek assurance.

Further work will include an analysis of the current suppliers who meet the turnover criteria, and for these organisations, a system will be put in place to gain assurance that the organisation complies with the Act or is working towards compliance, and thereby the College can seek assurance.

Additionally, through the College’s procurement activities, future tender documents will include a supplier Suitability Assessment Questionnaire to seek assurance before entering into new contracts.

Performance Indicators

Where the College has identified risks of modern slavery occurring in any part of its services, it will aim to introduce performance indicators (KPIs) to measure progress against reducing such risks. The College will consider setting and reviewing KPIs in the following contexts:

Use of Grievance and Whistleblowing Policies by staff to raise concerns about instances of modern slavery